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Policy Area

ESH-Environment Safety & Health

Procedure Number

ESH100.2.ENV.3

Procedure Title

Manage PCBs, PCB Containers, and PCB Sources Safely

Procedure Manager

PUISSANT, PAMELA M.

Status

Active

Subject Matter Expert

  • David H. Castillo
  • Mark E. Brynildson—CA Contact

 

Applicability, Exceptions, and Consequences

This corporate procedure applies to all Members of the Workforce who engage in activities at SNL/NM and TTR that involve the processing, use, and the accumulation of polychlorinated biphenyls (PCBs) or PCB items, or the request to dispose of them. At SNL/CA, PCB-related activities are performed in accordance with the requirements in ESH100.2.ENV.15, Manage Hazardous Waste at SNL/CA.

At KTF, Members of the Workforce follow U.S. Navy requirements and applicable Hawaii state laws.

At locations other than SNL/NM, SNL/CA, TTR, and KTF, the following requirements apply (in order of importance):

  1. State and local regulations applicable to the site.
  2. Requirements of the host facility.
  3. Requirements of this document when not in conflict with either of the above.

Exceptions to, or deviations from this procedure must be approved through the Executive Policy Sponsor or Policy Area Manager, if delegated. Click here to view Contacts for Corporate Policies, Processes, and Procedures.   See CG100.1.7, Request an Exception to a Policy, Process, or Procedure, for directions on how to obtain an exception to this procedure.

Granting or permitting exceptions or violations of policy, process, or procedure without authority, regardless of position or title, may be cause for disciplinary action up to and including termination of employment. Violating a policy, process, or procedure may be cause for disciplinary action up to and including termination of employment.

 

IMPORTANT NOTICE: A printed copy of this document may not be the document currently in effect. The official version is located on the Sandia National Laboratories Sandia Restricted Network (SRN).

Procedure Overview

This procedure addresses polychlorinated biphenyls—how to determine if items or substances contain PCBs and how to store and dispose of such material and report a PCB spill.

Procedure Requirements

Identification

Activity Responsible Individual Required Action
Determine Whether an Item Contains Polychlorinated Biphenyls Owners of oil or other substances, items, or equipment known or suspected to have been manufactured prior to 1980, that contain oil

Determine if the oil or other substances, items, or equipment contain polychlorinated biphenyls (PCBs) and at what concentration. This may be accomplished either by contacting the PCB program coordinator to request sampling and analysis or by reviewing the material safety data sheet (MSDS)—available at the Chemical Information System website—or other documentation, such as the name plate on equipment.

Note: Substances that may contain PCBs include, but are not limited to: dielectric fluids, solvents, heat transfer fluids, hydraulic fluids, paints or coatings, sludges, slurries, sediments, dredge spoils, soils, and other chemical substances or combinations of substances, including impurities and byproducts and any byproduct, intermediate, or impurity manufactured at any point in a process.

PCBs are most likely found in oil-filled electrical equipment (e.g., transformers, capacitors, fluorescent light ballasts), hydraulic systems, and heat transfer equipment manufactured before July 2, 1979. Most oil-containing equipment at SNL/NM and SNL/CA has been sampled to determine the PCB concentration, if any. Such equipment should already be marked with that information.
Determine Whether an Item Contains Polychlorinated Biphenyls Members of the Workforce
  • Assume capacitors manufactured before July 2, 1979, whose PCB concentration cannot be established, contain > 500 parts per million (ppm) PCBs. Capacitors manufactured after July 2, 1979, or marked at the time of manufacture with the marking “No PCBs” may be assumed as non-PCB (i.e., containing <50ppm PCB). Assume capacitors with an unknown date of manufacture contain >500 ppm PCBs.
  • Assume mineral oil-filled electrical equipment, other than capacitors, manufactured before July 2, 1979, whose PCB concentration cannot be established, contain >50 ppm and <500 ppm PCBs. Mineral oil-filled electrical equipment manufactured after July 2, 1979, may be assumed non-PCB. Mineral oil-filled electrical equipment with an unknown date of manufacture shall be assumed to contain >50 ppm and <500 ppm PCBs
  • Assume that all materials that come into contact with PCBs having a concentration >50 ppm are PCB contaminated and are managed according to the requirements of this section.
  • Inform the PCB program coordinator of all equipment identified to contain PCBs at >2 ppm.

Label Equipment

Activity Responsible Individual Required Action
Label Equipment Members of the Workforce

Label all containers and equipment identified as containing 50 parts per million (ppm) PCBs or greater with the ML marking (see Figure 1, Sample PCB ML Marking).

Note: This requirement applies to material and waste.
Managers or owners Ensure that equipment that has been determined to contain less than 50 ppm PCBs is marked with a PCB Survey Label (Figure 2) to prevent redundant identification. This label is provided and completed by the PCB program coordinator upon request.

 

 

Figure 1. Sample PCB ML Marking

 

Figure 2. Sample SNL PCB Survey Label and Tag

Use and Handling

Activity Responsible Individual Required Action
Use and Handle PCBs Members of the Workforce
  • Use PCBs or PCB items, regardless of concentration, only in a totally enclosed manner, unless you have documented permission to do otherwise from the PCB program coordinator.
  • To use PCBs in other than a totally enclosed manner, notify the PCB program coordinator who will determine if it is allowed and if it is, will provide specific regulatory requirements and documented permission. Note: It may be permissible to use PCBs in other than a totally enclosed manner if the following conditions are met:
    • PCBs are at concentrations less than 50 ppm and used in heat transfer and hydraulic systems
    • PCBs are used in specific authorized research development activities
    • PCBs are used in specific scientific instruments
    • PCBs are used as analytical reference samples.
  • Because of the difficulty and cost of cleanup and decontamination, handle PCBs and PCB items in a manner that prevents the spread of PCB contamination to equipment, structures, and other material.

 

Storage for Reuse

Activity Responsible Individual Required Action
Store PCB Articles for Reuse Owners of PCB articles that are in storage for reuse
  • Do not store PCB articles intended for reuse for more than 5 years from the date the article was originally removed from use.
  • Generate and maintain records, beginning when the PCB article is removed from use, and record in the record the following information:
    • The date the PCB article is removed from use.
    • The projected location and future use of the PCB article.
    • If applicable, the date the PCB article is scheduled for repair or service.
Store PCB Articles for More Than 5 Years Owners who intend to continue storing PCB articles past 5 years after the date they were originally removed from use Contact the PCB program coordinator at least 6 months before the end of the 5-year period for additional requirements.

30-Day Temporary Storage for Disposal

Activity Responsible Individual Required Action
Containing PCB Items Members of the Workforce
  • Place waste PCBs and PCB items in a container that is capable of preventing the spread of contamination unless the PCBs are completely contained by the item, such as totally enclosed electrical equipment.
  • Place waste contaminated items, such as personal protective equipment (PPE) and rags, in a sealed plastic bag with a minimum 6-mil thickness to prevent the spread of contamination.
Using 30-Day Temporary Storage Members of the Workforce
  • Store PCB waste at a 30-day temporary storage area limited to the following types of PCB waste:
    • Non-leaking PCB articles and PCB equipment
    • Leaking PCB articles and PCB equipment only if the items are placed in a non-leaking PCB container that contains sufficient sorbent material to absorb any liquid PCBs remaining in the items
    • Containers of non-liquid PCB waste, such as contaminated soils, rags, and debris
    • Containers of liquid PCB waste with a concentration between 50 and 500 ppm at the direction of the PCB program coordinator.
  • Comply with the following requirements for 30-day temporary storage of PCB waste:
    • Mark the storage area with the ML marking (see Figure 1, Sample PCB Marking).
    • Mark each waste PCB item or container with the date the waste was removed from service for disposal. The date must be clearly marked in plain view and be preceded by the words "Removed from service (date)."
    • Handle and manage PCB waste containers such that no PCBs leak out or contaminate any external surface of the container.
    • Store both liquid and non-liquid PCB waste in containers that meet DOT Packing Group III requirements.
    • Do not store PCB waste in excess of 30 days from the date it was removed from service for disposal. Note: To avoid exceeding the 30-day time limit, Members of the Workforce should request disposal of PCBs and PCB items within 20 calendar days of the removed from service date.

Disposal

Activity Responsible Individual Required Action
Requesting Disposal Owners of waste PCBs or PCB items with a concentration greater than two parts per million (ppm) Request disposal by submitting a completed Waste Description Disposal Request. Only waste PCBs and PCB items can be included on a single WDDR.

Spills and Leaks

Activity Responsible Individual Required Action
Reporting Spills and Leaks Owners of PCBs or PCB items that have spilled or leaked To report the spill or leak, immediately contact the PCB program coordinator or the SNL Emergency (911) or non-emergency hotlines (at SNL/NM 311 or 845-6515 and at SNL/CA 294-ESAH), as appropriate.
Handling PCB-Contaminated Items Members of the Workforce
  • Determine if a surface is contaminated by assuming that all surfaces that come into contact with PCBs with a concentration of 50 parts per million (ppm) or greater are PCB-contaminated.
  • Manage and dispose of such items in accordance with this procedure.

Note: Examples of PCB-contaminated items include, but are not limited to PPE, cleanup material, and hand tools.

 

Implementing Tools

Websites:

  • Material Safety Data Sheet - Chemical Information System.
  • Waste Description Disposal Request.

Required Records and Retention Schedule

Managers must ensure that the records specified below are managed in accordance with the Sandia Records Retention and Disposition Schedule. Required records are listed below. The applicable Sandia record series number is in parentheses. 

  • Chemical Waste Disposal Request Records (EN-170-203-000).

Additional Drivers

  •  40 CFR 761, Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce and Use Prohibitions.

Training Requirements

Responsible Individual Required Recommended
Members of the Workforce who process, use, accumulate, or request disposal of PCBs N/A ENV190

 

Related Processes and Procedures

Process

  • ESH100.2, Analyze and Control Hazards.

Procedures

Change Summary

Date Summary
08/23/2011

Administrative

Modified

Updated link to PCB program coordinator in Requirements & Instructions.
07/26/2011

Administrative

Modified

  • Replaced James Thompson with Pamela Puissant as procedure manager.
  • Updated SAPLE links to subject matter experts for system consistency
  • Updated dictionary links to term identification numbers for system consistency.
6/16/2010

Administrative

Added

  • Inserted new heading "Websites" under Implementing Tools.
06/07/10

Administrative

Removed

  • Web Content Manager test text
04/12/10

Administrative

Removed

  • Web Content Manager test text.